How should you approach your application for authorisation? The key is to plan to become compliant. The first step is to plan your authorisation project and to determine who in your firm needs to be involved.
In addition to assembling a good deal of factual information (financial and non-financial) required by the FSA, the main elements of the project are:
This process will help you determine who will have to be nominated to the FSA as "approved persons". The FSA's statements of principle and code of practice for approved persons (APER) sets out the standards that your directors and key senior personnel must meet to obtain individual approval by the FSA and by which they must operate thereafter.
It is evident that the authorisation project should be managed by a team involving staff from throughout the firm. It should be owned and managed "from the top", and have sufficient clout and resource to do the job. The objective must be to ensure that regulatory requirements, and in particular the high level "principles for business" are disseminated and understood throughout the firm.
Remember that observing these principles is a formal requirement. Firms and individuals may be disciplined by the FSA if it considers that these principles have not been observed - even where no detailed rule has been breached.
The FSA has been accepting applications since January. It has made clear that applications received later that 13 July may not be processed in time for 15 January 2005.
It is understood that only about one third of firms expected to seek authorisation have so far registered their interest.
Submitting the application is only the beginning of the process. By January next year you must be able to run you business safely and without fearing the regulator's knock on the door.